As a new foreign trade service provider driven by technological transformation and international trade, HiSiaddi has established a "1+2+3+4=1" service system and can supply raw materials of polybutylene succinate from multiple well-known original manufacturers. With over a decade of market experience and technological transformation cooperation with factories, HiSiaddi has rich expertise addressing product compliance issues. The following is a compliance handling case for polybutylene succinate by HiSiaddi.
Please contact HiSiaddi customer service if you need more consultation on PBAT product compliance issues.
HiSiaddi resolved four major compliance barriers covering REACH, EU food contact, EN13432, and customs classification in one-stop manner.
The buyer SwissEcoPack AG is headquartered in a premium environmental industrial park in Zurich, Switzerland, a leading domestic mid-to-high-end biodegradable food packaging manufacturer in Switzerland. Its products supply premium organic fresh supermarkets COOP Switzerland, high-end organic ingredient chains in France, and infant complementary food brands in Luxembourg, covering two core products: high-transparency ultra-thin food fresh-keeping films and biodegradable thermoformed infant complementary food packaging trays. All product lines comply with dual strict regulatory frameworks: stringent Swiss food regulations plus EU controls, with four mandatory market access thresholds: EU 10/2011 food contact materials directive, EU REACH chemical registration regulation, updated EN13432:2024 dual industrial & OK Compost Home compost certification, and EU PPWR packaging environmental regulation. The enterprise sourced premium imported European PBAT raw materials on an annual procurement volume of 290 tons.
Affected by rising local European chemical raw material prices and extended lead times, the client launched a localized procurement project for Chinese PBAT, finalizing a 65-ton initial order of food-grade film-blowing dedicated PBAT pellets from a domestic manufacturer, scheduled for shipment from Shanghai Port with transshipment via Rotterdam Port, Netherlands en route to Switzerland. On the eve of loading, four fatal compliance defects emerged: incomplete REACH registration of raw materials, mismatch between original certificates and actual shipment grades, food migration testing failing Switzerland’s stricter internal limits, and incorrect HS code classification risking customs detention upon export and failed clearance at the destination port. Without full compliance rectification within 15 days, the full container would incur high detention and warehousing charges, with estimated liquidated damages exceeding 42,000 EUR for delayed supermarket orders.
Recommended by the Swiss Packaging Industry Association, the client fully entrusted Shanghai HiSiaddi Technology with the full-process compliance rectification project. Our dedicated team of compliance legal specialists, polymer engineers, and customs practitioners decomposed and resolved all compliance loopholes item by item, completing rectification on schedule for customs clearance and shipment. The goods cleared customs smoothly and entered the warehouse, with a 280-ton annual long-term procurement framework locked subsequently.
Product Specifications: Food-grade virgin PBAT pellets Packaging: 25kg moisture-proof kraft bags lined with aluminum foil Original Declared HS Code: 390799; Corrected Precise Classification Code: 3913900000
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Incomplete REACH Regulatory Compliance with Unregistered Key Components The domestic supplier only completed basic REACH registration for the base substrate, yet seven auxiliary raw materials added during modification (food-grade anti-hydrolysis additives, high-molecular chain extenders, compliant lubricants) lacked separate EU REACH pre-registration, with no corresponding SDS chemical safety data sheets or substance registration numbers. Per EU REACH control rules, chemical pellets containing unregistered components are prohibited from entering EU territory, granting Swiss customs authority to detain, return, or destroy full containers. The original manufacturer could not complete supplementary registration documentation for additives within a short timeframe.
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"Certificate-Goods Mismatch" for EN13432 & OK Compost Certifications Rendering Certificates Invalid for Customs Clearance The TÜV-issued EN13432 compost certification and OK Compost Home household compost certification provided by the factory corresponded to a general injection-molding PBAT grade, while the actual shipment was customized premium modified film-blowing grade with inconsistent formulas and additive systems, leading to mismatched degradation indicators between certificate parameters and actual finished product testing. The EU adopted the updated EN13432 standard in 2025 with elevated biodegradation rate requirements (≥95% within 180 days), newly added earthworm ecotoxicity testing, and tightened trace heavy metal limits (lead reduced to 20mg/kg). The manufacturer’s outdated certificates failed to meet new regulatory standards and could not serve as customs clearance documentation for Swiss import entry. Unfamiliar with differences between Chinese and European certification rules, the client finalized the order relying solely on written manufacturer commitments without pre-verifying matching between certificates and physical shipment grades.
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Non-Compliant EU 10/2011 Food Contact Performance with Excessive Migration Under Swiss Local Testing The original supporting SGS food migration test reports were conducted per national GB 4806.7 standards without benchmarking Switzerland’s stricter internal limits exceeding EU baseline thresholds. Two indicators (total migration upon immersion in acidic food ingredients and trace additive precipitation) exceeded Swiss import control limits, with additional restrictions applicable to infant packaging subcategories. No retest reports recognized by Swiss LFGB equivalent standards were available. Part of the lubricant additives used in the manufacturer’s formula were not listed on the EU 10/2011 permitted ingredient inventory—should random inspection fail upon import entry, the full batch of raw materials would be prohibited from production and forced to return.
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Incorrect HS Code Classification Risking Customs Detention During Export Declaration The factory self-declared HS code 390799 (general polyester chips). This tariff code carries inconsistent tariffs, inspection requirements, and export supervision conditions compared to biodegradable PBAT raw materials. Classification under 390799 fails to reflect fully biodegradable properties, leading EU importing countries to impose ordinary plastic import tariffs nearly 6% higher than the compliant code 3913900000. Additionally, biodegradable product-specific inspection filing was absent, and the domestic customs broker warned the code would likely trigger customs inspection and detention, preventing normal loading and shipment.
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HiSiaddi formed a dedicated cross-functional team of compliance legal staff, material technologists, and customs operators, dividing four rectification modules with reversed delivery timelines, coordinating third-party authoritative testing institutions, TÜV certification bodies, customs classification consultants, and upstream raw material manufacturers for synchronous implementation.
1. REACH Compliance Completion: Supplement Additive Registration Documentation & Standardize SDS Files
· HiSiaddi sorted the complete additive list of the modified formula, screened alternative compliant additives already holding EU REACH pre-registration status, coordinated the factory to replace three unregistered additives, and supplemented pre-registration certification for four remaining auxiliary materials eligible for expedited documentation.
· Collaborated with local EU compliance institutions to issue REACH pre-registration receipts for additives and full English SDS chemical safety data sheets, marking EC numbers, CAS numbers, and registration status for each chemical substance.
· Compiled consolidated REACH Declaration of Conformity (DoC) formatted per Swiss customs requirements, listing substrate and additive registration information item by item, with documents submitted concurrently to the client for Swiss import filing.
1. Composting Certification Rectification: Certificate Renewal & Batch-Specific Testing to Achieve Certificate-Goods Consistency
· Coordinated the original manufacturer to send samples of the shipped film-blowing PBAT grade to TÜV Austria laboratories for expedited full testing against the updated EN13432:2024 standard covering four core items: biodegradation rate, disintegration rate, heavy metal limits, and earthworm ecotoxicity. Expedited enterprise green channels delivered special batch test reports and temporary customs clearance approval letters within seven working days.
· The manufacturer simultaneously initiated OK Compost Home certification renewal for this grade, with HiSiaddi issuing an official product grade-certificate matching statement sealed by TÜV, granting temporary customs clearance documentation recognized by customs authorities across the entire EU and meeting Swiss import inspection requirements.
· Uniformly printed compliant "INDUSTRIAL & HOME COMPOSTABLE" logos on all outer packaging bags per new EU regulations to avoid penalties from non-compliant labeling.
1. Food Contact Compliance Optimization: Formula Fine-Tuning + Retesting to Meet Swiss Recognized Laboratory Standards
· HiSiaddi material engineers optimized the product modification formula, eliminating additives outside the EU 10/2011 permitted inventory and replacing them with EU & Switzerland dual-approved food-grade plant-based lubricants.
· Samples were submitted to SGS Shanghai laboratories holding Swiss LFGB accreditation for retesting of total migration, heavy metals, and monomer residues per Swiss import internal control standards, with bilingual test reports issued after full compliance verification.
· Compiled a bound archive of EU 10/2011 Declaration of Conformity, formula component lists, and test reports as core documentation for the client’s Swiss import filing of food raw materials.
1. Customs Code Correction: Precise Classification + Standardized Customs Documentation for Smooth Clearance
· Collaborated with customs classification specialists to revise the declared HS code from 390799 to 3913900000 (modified biodegradable polyester pellets) based on the product’s fully biodegradable properties, chemical structural formula, and national standard GB/T 41010, issuing customs pre-ruling consultation opinions.
· Recreated commercial invoices, packing lists, and foreign trade contracts with supplementary remarks on documents: fully biodegradable PBAT raw materials, EN13432 compliant, food-contact grade, with simultaneous completion of export inspection filing.
· All customs declaration documents and compliance certificates were uniformly archived and pre-submitted to domestic customs for preliminary review, passing one-time preliminary inspection without objections to schedule loading and shipment on time.
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Smooth Shipment of 65 Tons & Fast Swiss Customs Clearance Eliminating Massive Client Losses On the 14th day after rectification completion, the 65 tons of PBAT pellets were loaded and shipped from Shanghai Port with full compliance documentation accompanying the goods. Upon arrival at Rotterdam Port for transshipment to Zurich, Switzerland, complete REACH, composting, and food compliance documentation enabled customs clearance and warehousing within three working days without any inspection or detention. Raw material deployment enabled full-capacity production of the client’s infant complementary food packaging and fresh-keeping film lines, facilitating on-time delivery of COOP supermarket orders and eliminating 42,000 EUR in potential breach penalties. The procurement cost of optimized domestic raw materials dropped by 28.5% compared to imported European alternatives, and ocean transit cycles were shortened by 40 days.
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Signing of 280-Ton Annual Long-Term Procurement Framework Appointing HiSiaddi as Exclusive Compliance Service Provider Forty-five days after rectification delivery, SwissEcoPack AG signed a 280-ton annual PBAT procurement agreement with HiSiaddi with the following stipulations: HiSiaddi conducts full-process pre-compliance audits for all batches of domestic PBAT raw materials, covering raw material selection, formula compliance, certificate verification, customs classification, and import filing to eliminate certificate-goods mismatch and regulatory non-compliance risks at the source. Pre-delivery pre-audits covering REACH, food contact, and composting compliance are mandatory for every shipment. The client later entrusted HiSiaddi with upfront compliance review and raw material selection for new high-end biodegradable pet snack packaging R&D projects.
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Benchmark Case Radiating Mid-to-High-End Packaging Clients Across Western Europe Supported by this successful Swiss compliance breakthrough case, HiSiaddi leveraged its full-chain compliance service capabilities to connect with two equivalent mid-to-high-end organic packaging enterprises in Belgium and Finland via the client’s industry resources, replicating the standardized service workflow: upfront compliance audit + formula compliance optimization + certification delivery + customs classification, securing multiple batches of PBAT foreign trade orders and consolidating HiSiaddi’s compliance service moat in Western Europe’s high-end biodegradable raw material market.
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Most domestic PBAT manufacturers focus on the domestic market with insufficient awareness of segmented EU regional regulations (Switzerland’s stricter food clauses, updated EN13432, REACH additive registration, PPWR packaging new regulations). Common industry deficiencies include indiscriminate reuse of universal certificates, inadequate control of additive compliance, and arbitrary HS code declaration. Mid-to-high-end European and American food packaging clients enforce zero tolerance for raw material compliance per stringent local food safety and environmental regulations; mismatched certificates, non-compliant formulas, or incomplete documentation easily trigger full-container detention, return shipments, and substantial liquidated damages.
Traditional foreign trade service providers only offer raw material sourcing without integrated cross-disciplinary capabilities covering compliance, material technology, and customs brokerage. Breaking the model of pure raw material intermediation, HiSiaddi centers on upfront compliance control to close the full industrial chain loop: formula rectification, international certification, chemical registration, and customs classification. We compensate for compliance shortcomings hindering domestic raw material exports to high-end European markets, helping overseas mid-to-high-end clients evade import regulatory risks while supporting high-quality domestic PBAT products to enter Western Europe’s premium food packaging supply chains in full compliance—this constitutes the core path for domestic biodegradable materials to break through overseas green trade barriers.
Please contact HiSiaddi customer service if you need more consultation on PBAT product compliance issues.
+86-13120989737 
info@hisiaddi.com 
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